Galbreath v. Commissioner
United States Tax Court
Petitioner, an air traffic controller, took flight training courses that culminated in his receiving a private pilot's license and instrument rating certification. Held, the private pilot's course maintained and improved his skills as an air traffic controller and therefore that cost of such course is deductible as an educational expense.
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Petitioner, an air traffic controller, took flight training courses that culminated in his receiving a private pilot's license and instrument rating certification. Held, the private pilot's course maintained and improved his skills as an air traffic controller and therefore that cost of such course is deductible as an educational expense. Held further, the instrument rating course maintained and improved his skills but its cost is nondeductible as an educational expense because the training qualified him for a new trade or business. Sec. 1.162-5(b) (3), Income Tax Regs.
1Opinion of the Court
MICHAEL F. GALBREATH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Galbreath v. Commissioner
Docket No. 1060-81.
United States Tax Court
T.C. Memo 1982-540; 1982 Tax Ct. Memo LEXIS 201; 44 T.C.M. (CCH) 1163; T.C.M. (RIA) 82540;
September 21, 1982.
Petitioner, an air traffic controller, took flight training courses that culminated in his receiving a private pilot's license and instrument rating certification. Held, the private pilot's course maintained and improved his skills as an air traffic controller and therefore that cost of such course is deductible as an educational expense.…
2Cases cited14 opinions
- Davis v. CommissionerUnited States Tax Court · 1976
- Weiszmann v. CommissionerUnited States Tax Court · 1969
- Carroll v. CommissionerUnited States Tax Court · 1968
- Manocchio v. CommissionerUnited States Tax Court · 1982
- Ronald F. Weiszmann and Deborah C. Weiszmann v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
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